Federal Real Estate and Partnerships Tax Conference 2025 (Presented by NYU School of Professional Studies)

This session addresses the complexity of current year shifts in appreciation of partnership assets that occurred in prior years. Topics include capital shift taxation, the varying interest rule under Section 706, and the crystallization of promote interests into capital accounts with liquidation value.

This presentation focuses on minimizing estate and gift taxes for real estate entrepreneurs through entity restructuring and gifting techniques. Key topics include grantor trust planning, valuation discounts, spousal lifetime access trusts, and sale-leaseback transactions for personal residences.

This session examines federal income tax ramifications of landlord-tenant lease negotiations in tenant-favorable markets. Topics include Section 467 rental agreements, tenant improvement allowances, leasehold inducement payments, and the critical determination of tax ownership for improvements.

This interactive session provides an outstanding opportunity for the audience to raise tax questions with a panel of leading experts. Panelists draw from their extensive experience in partnership taxation, real estate transactions, and complex deal structuring.

This panel discusses top negotiation items between joint venture parties and common drafting mistakes in partnership agreements. Topics include layer cake versus targeted allocations, Section 704(c) elections, debt allocation language, tax distributions, and partnership representative provisions.

This panel covers recent developments and trends involving like-kind exchanges of real property. Key issues include DST considerations, dealer property characterization, construction exchanges, tenants-in-common structures, and parking arrangements within and outside safe harbors.

This presentation covers issues associated with troubled businesses and debt restructuring with a focus on partnerships and real estate. Topics include foreclosure tax treatment, Section 108 exclusions, qualified real property business indebtedness, and A/B note structures in workouts.

This session covers creative real estate deal structures related to joint venture entry and exit transactions. Topics include recapitalizations, revaluations, preserving negative capital accounts, debt and equity planning, and REIT planning strategies.

This panel discusses hot topic accounting method opportunities to optimize cash flow for real estate businesses. Strategic considerations and planning actions are examined in advance of potential tax reform legislation in 2025.

This presentation discusses navigating BBA partnership audits, which are among the lengthiest and most complicated IRS administrative proceedings. Guidance is provided on efficiently managing audits amid IRS staffing uncertainty and changing agency priorities.

This presentation focuses on current key national public policy issues and legislative actions under consideration affecting the real estate industry. The discussion covers potential regulatory changes and their impact on the overall economy.

This presentation discusses structures to own US real estate in a tax-efficient manner for non-US investors. Special concerns are addressed when non-US persons become partners in partnerships or investment funds owning US real estate or mortgage debt.

This presentation focuses on how partnership debt allocation rules operate in entities structured as partnerships and LLCs. Discussion includes the recent final related party debt allocation regulations and their practical implications for real estate transactions.